difficult to determine how much money is spent by the aerospace industry itself, the total for both government and industry is probably below $100 million a year. Presumably this total will decrease when work is finished on the acoustical nacelle research, the front fan and the quiet engine program. At that time, unless something is done, the country will lack a well rounded R&D program, which assures the public that the next generation of aircraft will not produce unacceptable environmental intrusions.

Doesn't it seem imprudent to make expenditures ranging from $500 million into the billions of dollars in order to produce a few decibels of noise reduction, which may or may not be perceptible, when at the same time there is no program for insuring that future aircraft will operate at acceptable noise levels?

To put this another way, billions could be spent on retrofit or refanning programs; yet by 1980 the public could be just as unhappy with us and with the government as it is today. On the other hand, a well rounded R&D program would probably not require more than $200 million to $300 million. From this we could be assured that future aircraft would be the good neighbors that we talk about so frequently.

It is not my purpose to try to persuade the Committee what the answers to these important questions should be; however, they deserve careful examination as vital issues of public policy.

That concludes my statement, Mr. Chairman.

Thank you for your time.

Senator CANNON. Well, thank you very much for an interesting presentation. I might say that you have raised a very good point in the charts you have attached and one which Mr. Skully alluded to when he said that he was surprised at Mayor Mergell's statement this morning.

The implication there, which I think your statement seems to support, was that even if you reach the noise level that is covered by the DC-10 and L-1011 by putting into effect all of these programs, those permissible noise levels are not going to be acceptable to the public.

Mr. VON KANN. Well, this could well be and, of course, I think the DC-10 is below part 36. So, that just compounds the question.

Senator CANNON. Yes. It is below part 36 and, of course, if your suggestion is followed there for more thorough R. & D. far out in the future, that does not help the people that have the noise problem today, and I think as you understood it, perhaps, the best results for the immediate future are possible from operational procedures rather than the talk about the retrofitting and nacelle treatment and so on.

Mr. VON KANN. Well, we certainly think that they deserve consideration and we are working hard on them.

Now, there is a tendency, of course, for the concern with approach to be oversold. It is not too difficult to do that with a fleet such as the PSA fleet where you have got a small number of pilots, one kind of aircraft, a limited number of airports.

You can train your crew so that there will be a great deal of confidence quickly. In the case of the overall system where you are

going to have to do it all over the country, and be sure that your pilots are standardized, that you have the right equipment in the cockpit and possibly you will have to have DME's on the ground at the glide slope shacks.

It is not going to come that fast, but we do have the work going on now with the United 747's. We hope soon to try the DC-8, which, again, in all frankness, may or may not lend itself to this technique because the DC-8 is such a clean aircraft that we are not sure what might happen if you nose it down to 6 degrees. It might go too fast.

In fact, we should push as hard as we can because in an area like this, it so happens that I think the people beyond the yellow marker would feel-recognize that things are quieter. At the same time, to be quite honest and lay all of our cards on the table, one must admit that from the outer marker on in they are flying basically about the same glidepath and there is an area where you just cannot do much good unless you get into land use measures, or cut down your operations.

Senator CANNON. Senator Tunney?

Senator TUNNEY. Thank you, Mr. Chairman.

When we are talking about decibel levels, we are talking about a logarithmic scale and that is an increase of 10 decibels as a 100-percent impact on the human ear. I was just noticing in your statement, when you are talking about getting to within three or four EPNdB's of part 36, what you are actually talking about is still having to get 40 percent of the way down to achieve those part 36 standards.

So, for the person living in the vicinity of an airport, it could be quite obnoxious and quite difficult for them to accept the fact that you have still got three or four or five EPNdB's to go.

Mr. VON KANN. That is true.

Senator TUNNEY. I was impressed by one part of your statement, particularly, and that is your saying we ought to do more research and development on what the public finds acceptable in the way of noise before we start spending hundreds and millions of dollars on a retrofit program that may not prove successful.

I listened to a tape recording of a nacelle quiet engine a couple of hours ago, and I must say that I didn't think it reduced the noise level that much over what exists now.

I was thinking of the JT-3(d) engines. I am concerned about the idea of spending hundreds of millions of dollars on a program of retrofit which is just not going to be successful. We hold out false promises to the public that it is going to be successful and it is not successful.

That is why I am very deeply concerned about the funds cut back. It seems to me that if anything we ought to be spending more not less money on R. & D. to develop the technology to develop lower aircraft engine noise levels.

I am pleased to see in your statement that you feel the same way. You say $200 to $300 million a year. Are you talking about a total program of $2 to $3 million, or are you talking about $2 to $3 million a year?

Mr. VON KANN. Well, I think a total program of that magnitude will do a great deal. We are attempting to get some better estimates from our engineers, but I think we are

Senator TUNNEY. Over what, a period of 2 or 3 years?

Mr. VON KANN: No. I think we have to be talking about 5 years to really try all of the expedients, flight test them. Again, the faster you have got to do it, the more expensive you make it. That is one of the problems.

Senator TUNNEY. Well, of course, you are pushing it out to 1978, and there are an awful lot of people that are going to be long since gone that are being disturbed right now by noise. I think that we do need a crash program.

I just cannot help but believe that we do need a crash program. If you live in a community like Inglewood, you realize how important it is.

I like the fact that you have seriously addressed this problem. I think your association can make a significant contribution and I hope that you keep pressure on the Congress as well as the administration with respect to R. & D. because you have been helpful in that.

We have worked with you in the last few months on this goal and you have objected to the cutback as we have and I think that is important.

Mr. VON KANN. Well, we will continue to object and we will also try to lay out the kind of a program which this crash program might be and you can be assured that we will be pushing on that.

Senator TUNNEY. Is the ATA doing anything to help EPA with the study?

Mr. VON KANN. Oh, yes.

We are participating in all six task forces. As a matter of fact, I had an opportunity to talk to Doctor Meyer at the luncheon break and he indicated to me that he was quite happy with our work.

We will continue to push as hard as we can.

Senator TUNNEY. Good. I hope that you will be joined soon by the FAA.

Mr. VON KANN. I think that will work itself out soon, sir. Senator CANNON. Thank you very much, General von Kann. [The statement follows:]

STATEMENT OF CLIFTON F. VON KANN, SENIOR VICE PRESIDENT-OPERATIONS AND AIRPORTS, AIR TRANSPORT ASSOCIATION OF AMERICA

My name is Clifton F. von Kann. I am Senior Vice President, Operations and Airports of the Air Transport Association of America, the trade and service organization representing virtually all of the scheduled, certificated airlines in the United States.

The airlines appreciate the opportunity to participate in these hearings. It is good that they should be held here. California has demonstrated great concern for the environment, and so much of the technological base for preserving and improving the environment exists here in this great State.

Also it is a happy fact of economic life in Los Angeles that it is an important aviation hub-both for commercial air travel as well as private flying. It is happy because it means that the entire Los Angeles area is enriched by some $3.6 billion annually from aviation activity. Of this $3.6 billion, about $2.3 billion flows from Los Angeles International into the surrounding community. $1.4 billion of this money is in payrolls at Los Angeles International whose purchases amount to about $260 million and whose local tax bill is more

than $25 million. Moreover, the air visitors who pass through Los Angeles International spend approximately $1.6 billion, all to the benefit of the local

economy.

Now let me say a few words about the airline approach to environmental matters in general, and noise in particular. This is fundamental to consideration of the aircraft noise issue in toto.

1. The airlines have little control over airport location, configuration, clear zones or other land use factors. Airlines have been among the strongest pleaders for compatible land use measures, but little has been done except in one or two states to establish adequate land use laws. In this important area we seemed doomed to wait for action state by state. This, presumably, will take many years.

2. The airlines have little control over the technology incorporated in their aircraft. This is a job for the manufacturers, to whom we make known our desires; the airlines have done so by setting specifications which have resulted in quieter engines. Since there is a limit to the manufacturers' capability to engage in research and development, improvement in anti-noise technology comes slowly. We have long urged more extensive government research and development in this area to support the efforts which the manufacturers have made to date with their own funds. We have not urged that exorbitant sums be spent, but the actual funding level is inadequate.

3. Subject to F.A.A. regulation, the airlines do have some control over the flight paths used by their aircraft. This avenue offers substantial potential relief. We are actively exploring two-segment approaches as standard procedures that could be used throughout the system. This is not as easy to do system-wide as it is in a local situation; however, we feel that we are beginning to see progress. More on this later.

4. For more than 20 years the airlines have been concerned about the environment, noise in particular. Their record of action in these matters is a long one, and it is good. I will not attempt to detail it here, but will submit for the record a summary of airline environmental actions.

These being facts, we come here as frustrated as any one present that more has not been done and more progress toward meaningful noise alleviation has not been made. After all, the airlines, as much, if not more than anyone else, have a vital stake in reducing noise. They have a corporate obligation to protect the public health and welfare; the material I am submitting demonstrates that they have met this obligation. They have a responsibility for public safety; and their safety record speaks for itself. Finally, they have the duty to provide the public with safe, economical and expeditious air transportation as a vital part of the nation's economic growth. Noise creates great problems in all these areas and stands as the single greatest impediment to progress.

Today I would like to define the problem as precisely as possible-recognizing that this must be a mathematical approach-for want of more precise psycho-acoustical research, long recommended by the airlines. Then I will try to indicate what the several remedies under consideration can and cannot contribute to the solution.

The nearest thing we have to a national standard is FAR Part 36-which became effective December 1, 1969 and which prescribed certification standards for future aircraft. The new wide body aircraft generally meet these standards, and their noise is almost universally considered to be less offensive than that of the earlier jet aircraft. This is probably due less to the number of decibels than to the fact that the noise of these new aircraft is in a less annoying octave of the sound scale.

While Part 36 was originally directed at future aircraft, gradual improvements in anti-noise technology have raised the question whether we should change direction and try to bring the pre-Part 36 fleet down to or near Part 36 levels by acoustical treatment of engine nacelles (which I will call "retrofit") or converting the low by-pass JT3D and JT8D engines to higher. by-pass engines (which I will call "refanning"). You will note that I use the term "to or near Part 36 levels" because engineering estimates cannot be more precise than a probable error of about 3 EPNdB, because scatter makes it difficult to measure sound with greater accuracy than 3 EPNdB, and because under normal conditions the human ear cannot detect differences of 3 EPNdB. Now to define the problem I will use the general concept embodied in the recently proposed Fleet Noise Level (FNL) rule. While the airlines have many

reservations about the technical details of the FNL, the FNL formula offers a useful tool for analyzing where we stand in relation to Part 36 and where we are headed.

Figure 1 shows the actual total ATA FNL for 1972 in the takoff and approach regimes, which are all that are considered in the proposed rule. This is plotted against the FNL which would exist if all aircraft met FAR Part 36.

Assuming that no aircraft are modified but that all new 727, 737, DC-9 and 747 aircraft delivered after 1972 meet Part 36, Figure 2 is a plot of the ATA FNL for 1972, 1977 and 1982. This shows that while we would get "quieter" we would still exceed Part 36 noise levels in 1982. Figure 3 shows the noise gaps from Part 36 levels which would exist; note that the largest gaps are in the approach regime.

Now let us consider how the gaps might be closed. Several hardware possibilities exist-assuming that the R&D now underway on nacelle treatment and refanning verifies current engineering estimates on noise reduction to be achieved and on costs. Until this verification takes place, and until this hardware is certificated by F.A.A., no action is possible.

Suggestion 1: Assuming we replace all of the 707, 720 and DC-8 aircraft remaining in the fleet in 1977 or 1982, with new, quiet wide body jets on a 2 for 3 basis, Figure 4 shows the resulting FNLS. It also shows that, while we would achieve the Part 36 FNL in the takeoff regime, a gap would still exist in the approach regime. This would cost over $5.3 billion if accomplished by 1977, or $3.8 billion if accomplished by 1982.

Suggestion 2: It is obvious from the analysis of Suggestion 1 that the approach regime is the problem area and we will limit our subsequent analysis to that area. The FAA R&D is not as yet complete on the 707 aircraft, as flight tests do not start until April 1973. Nothing outside of commonality analysis of the potential use of the 707 modification has been done on the DC-8. Using predicted noise level reductions we find that if the FAA retrofit were installed on all JT3D powered airplanes, the gaps on approach FNL still exist as shown in Figure 5. Firm costs on these modifications are unavailable but are estimated to be about $327-467 million for the 1977 fleet, and $246-352 million for the 1982 fleet. All cost estimates are for hardware only and do not include labor, aircraft downtime, or higher operating costs, which could be substantial. Higher fuel consumption would also result from this treatment.

Suggestion 3: The NASA new front fan program offers possible significant noise reductions for the JT3D and possibly the JT8D. If we should refan the JT3D powered airplanes the new FNLS for 1977 and 1982 would be as shown on Figure 6 for the critical approach regime. It can be seen that a gap would still exist between the Part 36 FNL and the actual FNL. This modification if applied to the 1977 fleet would cost about $766-934 million. If applied to the 1982 fleet the cost would be about $580-704 million. Performance would be at least as good as at present.

Suggestion 4: It therefore becomes obvious that something must be done to the JT8D fleet to close the gap between the Part 36 FNL and actual FNL. Figure 7 shows what would occur if the JT8D fleet alone were retrofitted to meet Part 36. The cost would be about $164-196 million for the 1977 fleet or $151-179 million for the 1982 fleet. Again this is shown for the critical approach regime. The gap on approach still exists. Further analysis shows the gap would still exist if all the JT8D aircraft were modified to incorporate the new front fan at a cost of $1.699 billion if done on the 1977 fleet, or $1.681 billion for the 1982 fleet. It can thus be seen that selection of either the JT3D or JT8D fleet for retrofit or refanning, or even replacement of the JT3D fleet with wide body, quiet aircraft will not bring the fleet noise level down to the Part 36 level.

However, if both the JT3D and JT8D fleets were retrofitted with acoustically treated nacelles, the actual fleet noise level would meet Part 36. As indicated in Figure 8, this would cost $491-$663 million and would involve increased operating costs, fuel increases of 100-150 million gallons per year, and increased engine emissions.

Considerable doubt has been expressed that reduction of a fleet noise level to meet Part 36 would provide meaningful relief to the public. In the absence of solid knowledge of what is meant by "meaningful relief" we have strongly recommended additional government R&D to learn more about the subjective re